Program Eligibility—Sponsors
This is part one of a series of presentations that will provide an overview of planning and administering the Summer Food Service Program or SFSP. In this presentation, we will look at sponsor eligibility.
First of all, who are sponsors? Sponsors are local, public or private, nonprofit organizations who administer the Summer Food Service Program. Some examples might include: a public nonprofit school food authority or SFA; a unit of local county municipal state or federal government; or any other type of private nonprofit organization.
Organizations that want to become sponsors apply and are approved by the state agency. They then sign program agreements with their state agencies and are responsible for operating the program. Sponsoring organizations must be tax-exempt and must demonstrate the administrative and financial ability to manage a food service effectively. Sponsors receive Federal reimbursement from the state agency to cover the administrative and operating costs of preparing and serving meals to eligible children at one or more meal sites.
As a sponsor, your organization at a minimum is expected to: attend state agency trainings; locate and recruit eligible sites; hire, train, and supervise staff and volunteers; competitively procure food to be prepared or a vendor for meals to be delivered; monitor all sites; prepare claims for reimbursement; ensure that the sites are sustainable ; and maintain all program documents for three years plus the current year.
For organizations not yet ready to take on these responsibilities, another option is to participate as a site under an existing sponsor. This is an effective way to prepare an organization to become a sponsor in future years.
To be deemed eligible, sponsors must meet the following requirements: 1) Potential and returning sponsors are required to demonstrate that they have the necessary financial and administrative capability to comply with program requirements. They must accept full financial and administrative responsibility for all of their sites.
2) Applicants must not have been declared seriously deficient or terminated from the SFSP or other child nutrition programs in previous years. However, such an applicant may be approved if the state agency determines that it has taken appropriate corrective actions to prevent recurrence of the deficiencies and has repaid any outstanding debts.
3) Sponsors must agree to provide regularly scheduled meal service for children in designated areas in which poor economic conditions exist or they must agree to serve low-income children. Camps do not need to meet this criterion.
4) Sponsors must conduct a not-for-profit food service through SFSP. A sponsor is operating a non-profit food service if the food service operations are principally for the benefit of participating children and all of the program reimbursement funds are used solely for the operation or improvement of the food service. This does not mean the program must break even or even operate at a loss but that all income must be used for the sole purpose of operating the nonprofit food service.
5) Sponsors must provide a year-round public service to the area in which they intend to provide the SFSP. State agencies may grant exceptions to this year-round service requirement for sponsors of residential camps migrant sites and in certain other limited circumstances.
6) Sponsors must demonstrate in their applications that they will exercise management control over the meal service at all of their sites. This means that the sponsor is responsible for maintaining contact with meal service staff ensuring there’s adequately trained meal service staff on-site and monitoring site operations. This management responsibility cannot be delegated below the sponsor level.
7) Prior to approval Sponsors must visit new sites and any sites that had operational problems in the previous year. 8) Approved sponsors must sign a written permanent agreement with the state agency.
Now, let’s take a look at additional eligibility requirements and flexibilities by sponsors type. School food authorities and other organizations currently in good standing in the National School Lunch Program, School Breakfast Program, or Child and Adult Care Food Program are not required to submit further evidence of financial and administrative capability when applying for SFSP participation. Typically, school food authority and Child and Adult Care Food Program institutions participating in other child nutrition programs have already demonstrated that they have the financial and administrative capability necessary to operate the program. These sponsors must be in good standing. That is they must have had no serious deficiencies declared in their most recent review cycle. However, the state agency has the discretion to deny the applications or require additional evidence from sponsors that have had significant problems operating other child nutrition programs.
When it comes to private nonprofit organizations special rules apply. These sponsors are required to be tax exempt. Although churches also must be tax-exempt, there is no federal requirement that they provide documentation of their tax-exempt status. All other private nonprofit organizations must provide documentations from the IRS of their tax-exempt status.
Experienced sponsors and sites in good standing, meaning those which successfully participated in the previous year with no serious deficiencies, only need to submit information that is likely to change from year to year and are not required to submit the same detail of organizational and operational information required of new sponsors.
The remainder of this presentation will address requirements for sponsors participating in other child nutrition programs. Some of these requirements may be different from what is required of sponsors not participating in other programs.
Sponsors participating in the SFSP in addition to other federal child nutrition programs, must meet requirements for dual participation in these programs. Other child nutrition programs include the National School Lunch Program (NSLP), the Seamless Summer Option (SSO), the Special Milk Program (SMP), and the Child and Adult Care Food Program (CACFP). We will now discuss specific requirements by program type.
Schools serving meals exclusively to children enrolled in academic summer school programs may receive reimbursement only through the National School Lunch Program and School Breakfast Program. If in addition to serving children enrolled in accredited summer school, the school plans to serve any children in the community at large, it may operate an open site through the SFSP. Schools that operate accredited summer school programs may not enroll in the SFSP as a restricted open site so that meals may be served only to summer school participants. This is an unauthorize use of the restricted site designation.
The Seamless Summer Option offers school food authorities an alternative option to the SFSP with streamlined administrative requirements. The SSO allows schools to provide free summer meals in low-income areas during the traditional summer vacation periods or for year-round schools, school vacation periods longer than 15 days.
Sponsors may elect to operate the SFSP at some of their sites while operating the Special Milk Program at other sites. However, a single site cannot simultaneously participate in both programs. Sponsors electing to administer the SMP must enter into a separate agreement with the state agency to operate the SMP at those sites or times when it is not participating in the SFSP.
Child and Adult Care Food Program institutions that develop a separate food service program for children who are not enrolled in the CACFP may be approved to participate in the SFSP as long as all other SFSP eligibility criteria have been met. Institutions that are approved for both the CACFP and the SFSP must ensure that the same children are not served meals in both programs and separate records must be kept for each program. Additionally, institutions may not switch back and forth between participation in CACFP and participation in SFSP to serve the same children. And institutions may not establish separate entities using separate tax identification numbers to serve the same children under different child nutrition programs, unless a legitimate need has been approved by the state agency.
CACFP institutions in good standing that want to operate the SFSP at the same sites where they provide meal service through the CACFP may follow the application requirements for experienced SFSP sponsors and sites instead of the application requirements for new sponsors and sites. This provision will be most applicable to At-Risk Afterschool Care programs or ASMP. Because most At-Risk programs may not receive reimbursement during the summer months, we encourage these programs to convert to the SFSP for the summer. In that case, they can serve the same children that they served during the school year. In other cases however, if CACFP institutions wish to participate in the SFSP they must serve children that would otherwise not be served under the CACFP. Institutions may not switch programs simply to receive a higher reimbursement in the summer months.
For additional information about the Summer Food Service Program, please contact your state agency.
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